Q1. Do you consider that the Local Plan meets the legal and procedural
requirements?

Yes

Q2. A local planning authority should submit a plan for examination which
it considers to be ‘sound’ – namely that it is; positively prepared, justified,
effective and is consistent with national policy. Do you consider the Plan has
met these tests?

Yes NoX

Please specify the reasons below

The plan is not sound because there is a major conflict between the policy of sustainability and the proposed unsustainable growth of the economy.

Q3. Please set out below any concerns you have with the Local Plan including any change(s) you consider necessary to address these concerns.

You will need to say how this change will address the concerns and it would be helpful if you could put forward your suggested revised wording to any policy or text and any evidence to support the change.

Please state which paragraph or policy your change refers to and specify the reasons below:

Document Paragraph number Policy number
Cornwall Local Plan – Strategic Policies 0 All
Sustainability Appraisal Report
Change:All occurrences of ‘economic growth’ to ‘economic growth manageable within sustainable limits’Evidence:Economic growth outside of sustainable limits is damaging because it is growth at the expense of next and future generations. Given that the enormously energy rich conventional fossil fuels have peaked in 2005 (see IEA reports for 2009 and later) and fossil fuel production is only being kept at current levels through highly polluting and depleting unconventional sources, such as tar sands, heavy oils, deep sea oil and shale oil, sustainable economic growth is highly unlikely to occur again until we switch our entire energy base to renewable technology. Therefore basing the whole Local Plan on future economic growth is unrealistic and is likely to mislead us into spending resources in areas that will contribute very little to future wellbeing of the population of Cornwall.Sources:http://www.transitionnc.org/node/50/1883#comment-1883

Document Paragraph number Policy number
Cornwall Local Plan – Strategic Policies 0 Objective 1
Sustainability Appraisal Report
Add:“and production of wood for construction and support for essential basic industries such as clothing and footwear manufacture”.Evidence:The Moors of Cornwall are highly suitable for re-forestation to produce all of local construction timber and biomass for heat and energy production. Currently underused, re-forested, these areas will greatly contribute to Cornwall sustainability and resilience.Clothing and footwear made from locally produced materials, such as hemp, would also greatly increase sustainability and resilience

Document Paragraph number Policy number
Cornwall Local Plan – Strategic Policies 0 Objective 3
Sustainability Appraisal Report
Change to:“Change retail provision to ensure that every food shop, including supermarkets, allocate at least 20% of their floor space to local producers in competition to the supermarkets own offer, under local producers control”.Evidence:Cornwall needs to change its retail model from the current highly unsustainable and utterly iresilient just-in-time warehouse stored model to locally multi-sourced model.

Document Paragraph number Policy number
Cornwall Local Plan – Strategic Policies 0 Objective 5
Sustainability Appraisal Report
Add:“Reduce the number of houses not in full time occupation and concentrate part time occupation in hotels, time-share and other commercial establishments”.Evidence:The massive expansion of second homes in Cornwall is destroying communities and depriving local people of affordable housing. Ensuring all houses are in full time occupation will reverse this damaging trend.

Document Paragraph number Policy number
Cornwall Local Plan – Strategic Policies 0 2
Sustainability Appraisal Report
Delete:“the most sustainable approach to accommodating growth”Add:“a sustainable approach to accommodating the improvement of well-being”.Evidence:Continuing growth is not possible if it involves the use of resources beyond their sustainable limits. “Sustainable economic growth” is an illogical term with no meaning. The economy cannot grow indefinitely on a finite planet or in finite Cornwall.Growth of quality of life and wellbeing needs to replace the current unsustainable emphasis on growth in material wealth. The aim of wellbeing is increasingly accepted as the way forward for regional and national policies. This is a key objective, for example, in Planning Policy (Wales). Health and well-being are covered in this Cornwall Local Plan in Policy 17. Because these are so important, we suggest that Policy 17 is renumbered as Policy 2.

Document Paragraph number Policy number
Cornwall Local Plan – Strategic Policies New paragraph before para 1 2
Sustainability Appraisal Report
Add:“Unsustainable development will not be supported. All jobs and businesses must be sustainable and appropriate, and be demonstrated to be so. All developments must be low carbon, and have built-in resilience to withstand the decline of resources such as oil and gas, and changes such as sea level rise.”Comments:Policy 1 is a presumption in favour of sustainable development; Policy 2 must make it clear that unsustainable development will not be supported.Unsustainable development would mean that Cornwall was being developed now at the expense of future generations, which is not acceptable.

Document Paragraph number Policy number
Cornwall Local Plan – Strategic Policies 1, 2 and 4 2
Sustainability Appraisal Report
After each target number (50,000 jobs, 420,000 sq m of employment floorspace, 42,250 homes) add:“(or a lower number if that is all that can be supported sustainably)”.Evidence:A Local Plan that contains figures that are outside the limits of the carrying capacity of Cornwall will not be sound. Complementary evidence on the sustainable carrying capacity of Cornwall should be provided. The target figures are too high against the Government statistical projections for households based on recent population and household census and other data. By 2020 in Cornwall they expect 255,240 households. This is an extra 24,000 households. The most recent figure for homeless people in Cornwall is 70 individuals.https://www.gov.uk/government/uploads/system/uploads/attachment _data/file/189965/AllTablesNonRegionalFinal__3_.xls

Document Paragraph number Policy number
Cornwall Local Plan – Strategic Policies 5 2
Sustainability Appraisal Report
Delete “wherever possible” before “adaptation to climate change”. Evidence:Adaptation to climate change is always possible and there should not be an implication that it is not always necessary.

Document Paragraph number Policy number
Cornwall Local Plan – Strategic Policies 8 2
Sustainability Appraisal Report
Add new paragraphs: “Fostering the development of Cornish food, building on the strengths of the Cornish food industry, which is becoming very successful. Support local food outlets in preference to increasing numbers of supermarkets.”“Construct new pumped storage facilities in the China Clay area for storing energy and better use of renewable energy resources. Construct similar sea pumped storage facilities at suitable places on the cliffs of North Cornwall”“Ensure that electrical power structure across Cornwall is sufficient to allow maximum development of all renewable energy sources. If necessary take over the power grid or finance the expansion of the power grid for a suitable return by charging for use”Evidence:Western Power is not keeping up with demand in expanding the power network and using unsuitable methods, such as charging the first renewable project for the whole cost of extension and subsequent projects nothing.Renewable energy is by its very nature variable and thus needs large storage capacity to make it efficient. Pumped storage is currently the most efficient method of electricity storage and the China Clay area and high cliffs are eminently suitable for that purpose.

Document Paragraph number Policy number
Cornwall Local Plan – Strategic Policies 5 2
Sustainability Appraisal Report
Delete “wherever possible” before “adaptation to climate change”. Evidence:Adaptation to climate change is always possible and there should not be an implication that it is not always necessary.

Document Paragraph number Policy number
Cornwall Local Plan – Strategic Policies 1 3
Sustainability Appraisal Report
This policy should be made more reflective of the sustainable development objective of the Plan and should be rewritten to show this.Evidence:Larger scale developments are not necessarily more sustainable and resilient than dispersed developments. Supporting larger scale developments may conflict with Policy 1, Policy 2 para 3, and Policy 17.Larger scale developments have specific problems including:o Increased local traffico Increased risk of flooding through increased surface coverageo Increased overcrowding at local schoolso Difficult to provide appropriate health service coverageo Lack of local shops and poor ability for community to develop strong community links (important for social resilience) Larger scale developments can be made more sustainable in urban areas by incorporating land for food-growing, natural wild areas, recreational areas and community buildings. Careful design of schemes can reduce the carbon footprint of a site and improve social cohesion.

Document Paragraph number Policy number
Cornwall Local Plan – Strategic Policies 3 3
Sustainability Appraisal Report
Add:“Small, local settlements (hamlets, eco-villages, cohousing groups and residential farms) living as close-knit communities, growing their own food and making better use of land and places, will be supported.”Background information: “A cohousing community is a type of intentional community composed of private homes supplemented by shared facilities. The community is planned, owned and managed by the residents – who also share activities which may include cooking, dining, child care, gardening, and governance of the community. Common facilities may include a kitchen, dining room, laundry, child care facilities, offices, internet access, guest rooms, and recreational features. Evidence:An example is seen in Tan 6 (One Planet Development) in Wales.

Document Paragraph number Policy number
Cornwall Local Plan – Strategic Policies 2 4
Sustainability Appraisal Report
Add words shown in inverted commas:Community facilities and local shops should, wherever possible, be retained “and new ones supported”.“The development of local crafts, local food and other industries and services that retain money in the local economy will be supported. Existing supermarkets will be encouraged to devote 20% or more floor space to local producers under local management to compete with supermarkets own offer”“New megastores will not be supported except in exceptional circumstances where it can be shown that:o No existing jobs would be losto A high proportion of goods sold will be locally producedo They are sited in existing town centres and will not compete with existing local stores”Evidence:o Tesco proposal at Machynlleth showed a net loss of 264 jobso Cornwall’s economy is very leaky - particularly for food and megastore purchases where all the profit goes out of Cornwall.o The local multiplier for Megastores has been shown to be only 1.6 compared to local shops where one study showed 10 x. Supermarkets, as currently managed, are bad for Cornwall.
Document Paragraph number Policy number
Cornwall Local Plan – Strategic Policies New para 5 5
Sustainability Appraisal Report
Add new paragraph 5:“Low carbon skills; renewable energy construction, maintenance and repair; sustainable building trades; basic clothing and footwear manufacture from local materials.”

Document Paragraph number Policy number
Cornwall Local Plan – Strategic Policies New para 3 6
Sustainability Appraisal Report
Add new paragraph 3:“All homes must be built to low carbon standards from now onwards, at least to Code 4 by 2014, moving towards zero carbon by 2016, which will greatly decrease cost of heating such homes and contribute to energy resilience in Cornwall.”Add:“Reduce the number of houses not in full time occupation and concentrate part time occupation in hotels, time-share and other commercial establishments”.Evidence:The massive expansion of second homes in Cornwall is destroying communities and depriving local people of affordable housing. Ensuring all houses are in full time occupation will reverse this damaging trend.

Document Paragraph number Policy number
Cornwall Local Plan – Strategic Policies New para 5 7
Sustainability Appraisal Report
Add new paragraph 5:“Small, local settlements (hamlets, eco-villages, cohousing groups and residential farms) living as close-knit communities, growing their own food and making better use of land and places, will be supported.”Evidence:This kind of development, by its nature, is resilient and sustainable. Cornwall could become a leader in supporting such sustainable settlements, such as Cottage Farm, Jacobstow, which runs entirely on renewable energy – heating, electricity, transport, lifestyle.Add:“Reduce the number of houses not in full time occupation and concentrate part time occupation in hotels, time-share and other commercial establishments”.Evidence:The massive expansion of second homes in Cornwall is destroying communities and depriving local people of affordable housing. Ensuring all houses are in full time occupation will reverse this damaging trend.

Document Paragraph number Policy number
Cornwall Local Plan – Strategic Policies 10
Sustainability Appraisal Report
Add:“A proportion of publicly-owned sites should be made available for allotments, food-growing, sports and recreational areas, wild natural areas, and community facilities.”
Document Paragraph number Policy number
Cornwall Local Plan – Strategic Policies New para 4 13
Sustainability Appraisal Report
Add new paragraph 4:“The design of all new buildings and settlements must take future resilience into account. Roofs should be south-facing or close to south-facing to enable solar panels to be added. Local food-growing areas should be included. Development Site assessments should take sea level rise, and surface flooding increases due to climate change, into account, and planning decisions will support a long-term aim to remove infrastructure and developments out of areas expected to be inundated within the next fifty years. New buildings should use locally produced wood, stone and other materials. Some of the moors should be re-forested to supply wood for construction and heating”

Document Paragraph number Policy number
Cornwall Local Plan – Strategic Policies New para 7 14
Sustainability Appraisal Report
Add new paragraph 7:“Economical and environmental barriers (such as natural willow walls) should be erected for all new developments over 5 houses by main roads, to protect dwellings from noise and particulate emissions from vehicles.”

Document Paragraph number Policy number
Cornwall Local Plan – Strategic Policies 3 15
Sustainability Appraisal Report
Remove last two paragraphs and add at the end:“All farms and settlements, including farms and small settlements in AONBs, will be permitted to have sufficient renewable energy equipment installed to at least meet their own energy needs. Permitted wind turbine noise levels at neighbouring sites will be raised from 35 decibels to 45 decibels. Renewable energy projects will not be rejected on the bases of ‘visual amenity’AONB status will not be a barrier to constructing renewable energy projects”Evidence:This would meet national renewable energy policies, allow self-sufficiency at the local level, support the localism agenda, and encourage rural sustainable development. 45 decibels is the noise level emitted by domestic kitchen appliances, such as fridges.Visual amenity is of far too low importance to use as a reason for rejection of vital increase in renewable energy capacity. Renewable energy and food production will be the dominant issues of the coming decades. It would be a grave mistake to use aesthetic objections to delay these important developments.See http://www.transitionnc.org/node/50/1883#comment-1883Please note:The box on page 31 is incorrect in stating Cornwall uses £500m worth of energy per year. It is actually around £1.6bn. (See REOC Cornwall’s energy bill.)
Document Paragraph number Policy number
Cornwall Local Plan – Strategic Policies 17
Sustainability Appraisal Report
(As mentioned above, we think that this should be policy number 2.)Add to the end of paragraph 1:“, climate change impacts such as storm surges and sea level rise and the expected ever increasing cost of fossil fuels.”Also, please ensure that the housing densities mentioned elsewhere are not in conflict with this policy.

Document Paragraph number Policy number
Cornwall Local Plan – Strategic Policies 1 20
Sustainability Appraisal Report
Add (after “realised”): “The Council will only support energy recovery facilities where:o The proposed technology is not incineration o The applicant has demonstrated actions to reduce waste arisings and increase recycling of all materials in the waste stream to be treated o Facilities also include high tech materials sorting planto The plant is of low impact”

Document Paragraph number Policy number
Cornwall Local Plan – Strategic Policies 2 20
Sustainability Appraisal Report
Add in front of present a-c:“A The proposal includes high tech sorting and cleaning plant through which all materials entering the site will passB Organic residuals from the sorting plant are composted and/or put through appropriate anaerobic digestion plant to reduce their BODC Food waste is allowed to be fed to omnivore domestic animals, such as pigs and chickens”

Document Paragraph number Policy number
Cornwall Local Plan – Strategic Policies 6 25
Sustainability Appraisal Report
Delete paragraph 6.Add (to replace the wording of paragraph 6): “Critical biodiversity should not be destroyed and important environmental and historical characteristics should not be sacrificed. The precautionary principle should always be followed, and critical natural capital should be preserved. Any mitigation agreed for non-statutory sites or non BAP species should provide additional habitat to that replaced.” Evidence:Mitigation of environmental assets may, in many circumstances, be contrary to existing legislation (e.g. the Habitats Directive) and environmental regulations. New work emerging from the Government shows the value to us all of natural capital which generally far outweighs the value of developments.We suggest the Council builds on national government work on Sustainable Development Indicators to develop appropriate Indicators for Cornwall and work with for example Defra’s Ecosystem Markets Task Force report April 2013.http://sd.defra.gov.uk/2013/04/realising-natures-value-ecosystem-markets-task-force-finalreport/?utm_source=feedburner&utm_medium=feed&utm_campaign=Feed%3A+gov%2Fsdscene+%28SD+Scene%29 Accepting money in exchange for damage to significant environmental heritage is unacceptable and should not be public policy.

Document Paragraph number Policy number
Cornwall Local Plan – Strategic Policies 1 26
Sustainability Appraisal Report
Change “take account of” to “follow”. Add at the end: “Development will not be supported on flood plains, areas likely to suffer increased surface flooding, or areas where an impact from sea level rise is predicted.”

Document Paragraph number Policy number
Cornwall Local Plan – Strategic Policies 1 27
Sustainability Appraisal Report
The Cornwall Transport Plan is not realistic as it is based on large traffic increases over the Plan period. The Transport Plan should be updated and only then used as the basis of this Core Strategy policy development. The new Transport Plan needs to take account of the new realities of resource depletion (especially the ongoing decline of the availability of oil) and the high and rising prices of transport fuels, which are already leading to a reduction in local transport fuel use.

Document Paragraph number Policy number
Cornwall Local Plan – Strategic Policies 3 27
Sustainability Appraisal Report
Add:“New classified roads will not be supported.”Evidence:The era of low-cost fossil fuels for personal transport has come to an end. This means that new roads are very unlikely to prove viable investments.

Document Paragraph number Policy number
Cornwall Local Plan – Strategic Policies 1 28
Sustainability Appraisal Report
Add:“No new classified roads will be approved, and local roads for new developments will not put car use at the centre of the developments. Infrastructure such as electricity supply, water supply and sewerage must be sustainable, low impact and low carbon and sited taking account of predicted changes in flood levels from climate change assessments.”“Council will ensure that adequate power lines infrastructure exists for all renewable energy developments, supporting these financially if necessary”

Document Paragraph number Policy number
Cornwall Local Plan – Strategic Policies 2 28
Sustainability Appraisal Report
Delete: “Contributions will be used to mitigate the impacts of developments (including any cumulative impact).”Add: “Critical biodiversity should not be destroyed and important environmental and historical characteristics should not be sacrificed. The precautionary principle should always be followed, and critical natural capital should be preserved. Any mitigation agreed for non-statutory sites or non BAP species should provide additional habitat to that replaced.” Evidence:Mitigation of environmental assets may, in many circumstances, be contrary to existing legislation (e.g. the Habitats Directive).Accepting money in exchange for damage to significant environmental heritage is unacceptable and should not be public policy.

Document Paragraph number Policy number
Cornwall Local Plan – Strategic Policies All PP
Sustainability Appraisal Report
All of these policies will require re-design in view of the above changes.

Q4. Did you raise this issue earlier in the plan preparation process?

Yes No X

If yes, please specify at what stage:

Q5. If your representation is seeking a change, do you wish to participate at
the examination in public?

No I do not wish to participate at the examination in public
Yes I wish to participate at the examination in public X

If you require any assistance in completing this form or require any further
explanation as to what is required please contact a member of the local planning
team using the email address below or telephoning 01872 224283.

Completed forms should be submitted:
by e-mail to: localplan@cornwall.gov.uk
by post to: Cornwall Council
Local Plans Team
Carrick House
St Clement Street
Truro TR1 1EB

Please submit any views to Cornwall Council using the above methods
by 5:00pm on 22 April 2013.

Next steps
The representations received during this formal round of consultation will be reported to and considered by the Council. Any significant changes will be consulted on prior to consideration by the planning inspectorate, who will appoint an inspector to conduct an examination in public.